BOI in 2026: who is exempt now, who still files, and who to stop paying
The BOI report went from 'the filing everyone owed' to 'the filing almost nobody owes — but many still get billed for.' Here's today's picture under FinCEN's interim rule, case by case, and the two warnings that keep you safe.
🌐 También en español: BOI Reporting 2026 para LLCs
What changed
The BOI (Beneficial Ownership Information) report was created so FinCEN knows who is really behind each company. It launched in 2024 covering almost every LLC and corporation. After court battles, the interim rule in force since March 2026 inverted the map: entities formed IN the United States became exempt, regardless of their owners' nationality.
Today's picture in one line: formed IN the US → exempt, no BOI. Formed in ANOTHER country and registered to do business in the US → still files.
Your situation, case by case
A Wyoming, Florida or Delaware LLC with a foreign owner: exempt under the interim rule. No filing, no updates — single-member, multi-member and corporations alike.
A foreign company registered to operate in a US state: this is the group that still files, with its deadlines and updates.
You already filed before the change: nothing bad happens. The filing stays archived and creates no new obligations while the exemption stands.
Someone is billing you for a BOI filing or update: before paying anything for a US-formed entity, ask under which rule they're demanding it. Some providers keep selling the filing as if nothing changed.
The two warnings
1 · The key word is INTERIM. The current rule is not final: FinCEN can adjust the scope in the final version. "Exempt today" gets re-verified before every important decision — never assumed forever.
2 · BOI was one layer, never the only one. Your foreign-owned LLC's annual Form 5472 (penalty from USD 25,000), the state annual report and the registered agent all continue exactly as before. The exemption changed one obligation — not your compliance calendar.
📄 Take this with you as a PDF
This article is also a free printable guide: BOI 2026: who is exempt now and who still has to file.
Your specific case?
Everything above is the general rule — real cases live in the details. In a 15-minute consultation (USD 29, credited toward any service) we review your situation and you leave with a concrete next step: book here →